I want to ask the EPA a simple question: who do you work for?

On Thursday, 11 August 2022 the Deputy Minister for Lands and Natural Resources, responsible for Lands and Forestry, Benito Owusu-Bio, was reported to have “cautioned individuals and groups winning sand on portions of the Amarhia Dairy Farm Lands in the Adentan Municipality of the Greater Accra Region to halt the illegalities. He warned that anyone found in the act would be prosecuted.”

Two weeks earlier, on 28 July 2022, Joy News broadcast a story under the headline, “Environmental pollution: Amrahia residents protest operations of a clay mining company in the area.”

Then on 4 August 2022, CitiTV which had also covered the story, broadcast its coverage under the headline, “Residents of Amrahia bemoan dust created by sand winning trucks.”

Where does the EPA feature in all of this? The sand-winning activities that the Deputy Minister cautioned against had been going on since September 2021, almost one year before the minister’s visit! Residents had endured unbearable dust pollution for almost one year, while government land that was originally acquired by the Nkrumah Administration for farming purposes had become a site for illegal sand-winning operations.

Residents had complained to different authorities about the illegal activities and especially about their exposure to health hazards caused by the sand and noise pollution from tipper trucks, and yet nothing had been done about the situation. I had personally complained to the EPA, and they did NOTHING about it. Why did I choose to complain to the EPA? In addition to its core functions, sand-winning is one of the undertakings that require registration and permit from the EPA before one can legally commence.

Under Section 2 of the EPA Act, 1994 (Act 490), the following are some of the functions of the EPA:

(d) to secure by itself or in collaboration with any other person or body the control and prevention of a discharge of waste into the environment and the protection and improvement of the quality of the environment.

(f) to issue environmental permits and pollution abatement notices for controlling the volume, types, constituents and effects of waste discharges, emissions, deposits or any other source of pollutants and of substances which are hazardous or potentially dangerous to the quality of the environment or a segment of the environment.

(j) to act in liaison and co-operation with government agencies, District Assemblies and any other bodies and institutions to control pollution and generally protect the environment.

(k) to conduct investigations into environmental issues and advise the Minister on these issues.

Also, Regulation 1(1) of the Environmental Assessment Regulations, 1999 (LI 1652) provides that:

“No person shall commence any of the undertakings specified in Schedule 1 to these Regulations or any undertaking to which a matter in the Schedule relates unless prior to the commencement, the undertaking has been registered by the agency and an environmental permit has been issued by the Agency in respect of the undertaking.”

Under Schedule 1(7) the following undertaking requires EPA registration and permit:

Sand and gravel pits -

(a) where the total area is greater than 10 hectares, or
(b) where any portion is to be located within an environmentally sensitive area.

EPA’s Inaction on Dust Pollution in Amrahia

• On Friday, February 11, 2022 - 08:11, I filed the following complaint with the EPA via its website complaint form:

Subject: Extreme Dust Pollution at Amrahia by sand winning near a residential area

Message: Dear EPA, I would like to bring to your attention an ongoing situation of extreme dust pollution caused by sand winning very close to a residential area in Amrahia, where I live. The sand-winning activities are taking place along the Amrahia-Danfa road, on the left side immediately after Regal Church.

Residents who live near the sand-winning base up to over 100 meters across the neighbourhood are affected by dust pollution. I would like to know if the EPA has issued permits for the Contractor(s) responsible. If not, then the EPA must move in immediately to stop their activities. Thank you.

• On 11 Feb 2022, at 08:11, Environmental Protection Agency, Ghana via Environmental Protection Agency, Ghana <Edmund.Mc-Addy@epa.gov.gh> wrote:

Thanks for your message!

We'll get in touch with you as soon as possible.

Best regards,

EPA Ghana

• Five months later, on 10 July 2022 at 08:38, I sent an email to the EPA as follows:

Dear EPA,

On February 11, 2022, I made a complaint to you about extreme dust pollution at Amrahia by sand winning near a residential area. Your auto-response said you will get back to me as soon as possible. Today is July 10, 2022, and I’m still waiting to hear from you, while the extreme pollution continues to affect residents.

Please act now!

• On 14 July 2022 at 07:20, I received an email from an EPA official:

Good morning Mr Kwaku Antwi-Boasiako,

Kindly visit https://complaints.epa.gov.gh/    to officially lodge your environmental issues

Thank you

• On the same 14 July 2022, I completed the new online form, amid lots of challenges because this was a new system they were piloting! Since the system did not allow me to submit images larger than two megabytes, I forwarded all images to the said EPA official via Whatsapp and also spoke to him on phone several times. He acknowledged receipt of the complaint and the images.

• On 27 July 2022 at 5:18 pm, I sent videos of a demonstration by the residents, who had blocked the road to the sand winning site, to the EPA official. The illegal sand winners had brought armed police officers to assist them to remove the roadblock and facilitating their illegal operations!

• At 5:47 pm on the same day, the EPA official responded:

“Will make a follow-up tomorrow please.”

• The following morning, 28 July 2022, there was another demonstration by the residents, so I sent the video to the EPA official and spoke to him on the phone. He promised the EPA will send personnel to the area to investigate my complaint. He even made me send him a location map via Whatsapp.

• At 6:05 pm on the same 28 July 2022 however, the EPA official sent me this message:

“the responsible department is quite occupied but will address the issue soon.”

• On 29 July 2022, around 1 pm, one of the residents got assaulted by one of the illegal sand winners. I sent the images to the EPA official and also called him. He told me he was going to send me a manual complaint form to complete. He added that I would need to gather signatures of the affected residents and bring both documents to the EPA offices the following Monday, 1 August 2022.

• I received the manual complaint form at 1:30 pm on 29 July 2022. There were no fields or separate forms for gathering the signatures of residents, so I sent the EPA official a message. His response at 4:14 pm was: “you will have to allow them to append them on a blank sheet.” At this point, I felt there was no need to waste any more time with the EPA.

When there is ongoing environmental pollution that is causing health issues for Ghanaian citizens, and there is environmental damage to lands belonging to the State (Amarhia Dairy Farms), EPA officials are too busy to respond to a formal complaint with images and videos, that they have acknowledged receipt of, unless the complainant fills a manual form, gather signatures of affected residents and bring same to the EPA’s offices, before the EPA can take any action?

Does the EPA work for the State, citizens affected by environmental pollution, the protection of the environment, or certain vested interests? Why did it have to take the Joy News and CitiTV coverage to prompt the visit to the area and the caution by the Deputy Minister in order to stop the sand-winning activities, when an agency with a legal mandate to protect the environment fails to perform its functions for whatever reasons? EPA, who do you work for?

Kwaku Antwi-Boasiako, Accra
August 16, 2022